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Basic Policy on Compliance with Competition Laws

Basic Policy on Compliance with Competition Laws

For information on the NIPPON PAPER GROUP compliance with competition laws, please refer to the following basic policy.


Based on the provisions of the Group Mission and the Charter of Conduct and the spirit thereof, NIPPON PAPER GROUP established a basic policy regarding compliance with competition laws in the relevant countries (including Japan).

  1. Compliance with competition laws in relevant countries
    Officers and employees*2 of the NIPPON PAPER GROUP*1 shall not engage in cartels, bid-rigging, or acts that may lead to suspicion of conflicting with the laws and regulations of the relevant countries (including Japan) among competitors or business associations.

  2. Contact with competitors
    You must not contact a competitor unless there is a valid reason. If you come into contact with a competitor, you will appropriately record and store the history and interaction. In addition, based on the fact that there is a suspicion that the activities of business associations are opaque and anti-competition, they are carried out in an extremely limited manner within the scope that does not raise doubts under the Competition Act.

  3. Agreements with competitors
    We will not enter into agreements*3 with competitors that hinder fair trade.

  4. Intervention in distributors, unfair discrimination
    The distributor shall not unreasonably restrict the price, quantity, sales area, business partner, sales method, etc. for transactions conducted by the distributor with its business partners. In addition, we will not unfairly discriminate against distributors regarding transaction terms such as price, quantity, and payment terms.

  5. Unfair Sale
    Do not sell products or services at unreasonably low prices that ignore profitability.

  6. Abuse of a superior position
    We will not use our superior position in business to impose unfair conditions on raw material suppliers, subcontractors, distributors, etc.

  7. Improper representation
    Do not make any indications or statements that are different from the facts, or exaggerate or unfounded representations or representations in sales or advertising activities.

  8. Implementation of education and training
    Based on these Guidelines, NIPPON PAPER GROUP regularly conducts education and training for its officers and employees in order to prevent violations of competition laws and maintain the appropriateness of business execution.

Above

  1. NIPPON PAPER GROUP: Refers to Nippon Paper Industries Co.,Ltd. and its subsidiaries (companies that control financial and business policy decisions, including indirect investment companies).

  2. Officers and employees: Directors andAudit & Supervisory Board Member, as well as executive officers, full-time employees,contract employees,part-time employeesdispatch employees, temporary employees, part-time employees, and other persons engaged in the work of NIPPON PAPER GROUP.

  3. Agreements that hinder fair trade: Typical examples are price cartels, bid-rigging, and segregation of markets, sales areas, and sales destinations. It does not matter whether it is written or oral.

Established on November 8, 29